On December 1, 2025, the California Air Resources Board (CARB) announced in an enforcement advisory that it would not enforce SB 261 against covered companies that do not submit climate-related financial risk reports (Risk Reports) by the January 1, 2026, deadline. This announcement follows the Ninth Circuit Court of Appeals’ (Ninth Circuit) injunction against the enforcement of SB 261 during the pendency of appellate proceedings in litigation challenging SB 261 and SB 253. For more information on the Ninth Circuit’s injunction, please see our client alert.Continue Reading CARB Announces Non-Enforcement of SB 261 Amid Ninth Circuit Injunction
SB 261
The Ninth Circuit Stays Enforcement of SB 261
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On November 18, 2025, the Ninth Circuit Court of Appeals (the Court) granted an injunction that stays enforcement of SB 261 while the Court reviews an appeal related to the ongoing litigation challenging SB 261 and SB 253 on First Amendment grounds. SB 261 requires public and private companies with…
Continue Reading The Ninth Circuit Stays Enforcement of SB 261CARB to Host Public Workshop on Implementation of California Climate Disclosure Laws
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On August 7, 2025, the California Air Resources Board (CARB) announced that it will hold a virtual public workshop on Thursday, August 21, 2025, from 9:30 a.m. to 12:30 p.m. Pacific Time “to support the development of California’s Corporate Greenhouse Gas Reporting Program.” This reporting program was established by Senate…
Continue Reading CARB to Host Public Workshop on Implementation of California Climate Disclosure LawsPreparing for SB 261: Climate-Related Financial Risk Disclosure Reports Due by January 1, 2026, for Covered Companies
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Our recent Client Alert provides an important update on SB 261, California’s Climate-Related Financial Risk Act. The California Air Resources Board (CARB), the regulatory entity empowered to implement SB 261, held a virtual public workshop in May 2025 and released FAQs in July 2025, to help companies prepare for compliance.
Continue Reading Preparing for SB 261: Climate-Related Financial Risk Disclosure Reports Due by January 1, 2026, for Covered Companies